On June 24, 2024, the EU adopted its 14th Russia sanctions package, including by amending Council Regulation (EU) 833/2014 (the “EU Russia Sanctions”), effective from June 25, 2024. The amending regulation is accessible here. The 14th package introduced several additional restrictions across different sectors, including: Enhanced anti-circumvention measures, including certain obligations on EU companies to undertake steps relating to their non-EU subsidiaries and counterparties to ensure compliance with EU sanctions; Enhancements to the requirements to…
The Office of Financial Sanctions Implementation (“OFSI“) published an update to the monetary penalties for breaches of financial sanctions guidance (“Guidance”) on 2 May 2024 (see here). The Guidance explains when and how OFSI will use its civil enforcement powers to impose monetary penalties for breaches of financial sanctions, including guidance on how such penalties will be calculated. The most recent changes primarily focus on Chapter 3 (Case assessment) of the Guidance. Following the recent update, OFSI…
On 14 December 2023, the Office of Financial Sanctions Implementation (“OFSI”) published its 2022-2023 annual review (see here). The review summarises OFSI’s activities over the 2022-2023 financial year and looks ahead at trends and OFSI’s priorities for the next year. Russia Sanctions The report has a particular focus on the UK’s expanded Russia sanctions regime, stating that by 31 March 2023, “130 oligarchs and family members” who had a combined net worth of around £145…
The UK’s Office of Financial Sanctions Implementation (“OFSI”) has published updated guidance (the “Russia Sanctions Guidance”) on the implementation of the Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), including a new FAQ addressing circumstances where a UK financial institution receives funds indirectly from or via a designated bank. In parallel with this update to its Russia Sanctions Guidance, OFSI has also published a new General Licence relating to Correspondent Banking Payments (INT/2023/3566356). Updated…